Heath Current v. HHS - Influenza, left shoulder injury related to vaccine administration (SIRVA) (2026)
Case summary [AI summaries can sometimes make mistakes]
On January 17, 2023, Heath Current filed a petition alleging that an influenza vaccine administered in his left deltoid on November 2, 2021 caused a shoulder injury related to vaccine administration. Mr.
Current reported that he felt instant pain and believed the shot was placed high. The first formal shoulder treatment came in January 2022, when he reported persistent left arm and shoulder pain from the flu shot.
Physical therapy records described pain reaching, lifting, pulling, dressing, driving for Uber, closing doors, steering, showering, lifting grandchildren, chores, snow removal, and sleep. He improved by March 2022, but symptoms returned in April and required a second round of therapy.
By May 2022, he was largely improved but not fully normal. Respondent disputed onset and damages, pointing to delayed care and a December 2021 annual exam that did not document shoulder complaints.
Chief Special Master Brian H. Corcoran credited Mr.
Current's declaration and contemporaneous later reports, found onset within 48 hours, and held that the Table SIRVA requirements were met. On February 6, 2026, he awarded $40,000.00 for pain and suffering plus $774.12 in unreimbursed expenses, for a total of $40,774.12.
Theory of causation
Influenza vaccine on November 2, 2021 causing left SIRVA; adult self-filed petitioner, exact age not stated; immediate onset credited. COMPENSATED after contested entitlement/damages. Key evidence: January 2022 first documented treatment but petitioner described instant high-shot pain; PT Jan-Mar and Apr-May 2022; limitations with Uber driving, showering, lifting grandchildren, chores, sleep; improvement by May 2022. Award $40,000 pain/suffering + $774.12 expenses = $40,774.12. Chief SM Brian H. Corcoran; petition January 17, 2023; decision February 6, 2026.
Source PDFs
USCOURTS-cofc-1_23-vv-00055